Privacy Policy

Your privacy is very important to us. This privacy policy discloses how Subway Franchise Advertising Fund Trust BV (“SFAFT BV”) collects, protects, uses and shares personal information gathered about you. All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. SFAFT BV respects the privacy of the customers and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies. Please note that this Privacy Policy does not govern the privacy policies and procedures of SUBWAY® stores.

WHAT IS PERSONAL INFORMATION?

Personal Information is any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to an Identification Number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: identifying information such as name, home address, home telephone number, e-mail address.

COOKIES – INTERNET USERS

In addition to Personal Information, we use data collection devices such as “cookies” on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

OUR USE OF YOUR INFORMATION

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

Currently, we do not ask of you to provide any personal information on our website. If this should change in the future, you will be notified of the changes on our website policy. Our website, however, may collect personal information without you having to enter any information, for example by use of “cookies”.

SHARING OF PERSONAL INFORMATION

We may share Personal Information with our service providers, consultants and affiliates. Except as described in this Privacy Policy, SFAFT BV will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. SFAFT BV reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. Currently, we do not share any of your personal information because you are not asked to provide any personal information on our website. If this should change in the future, you will be notified of the changes on our website policy.

STORAGE, RETENTION AND ACCURACY OF PERSONAL INFORMATION

SFAFT BV insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

SFAFT BV will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to ensure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

CONTACT INFORMATION

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee, affiliate or service provider to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: 0852-28062999; by Facsimile at: 0852-28871115; by email at: yuan_c@subway.com; or by mail at 13A, 9-21 Shell Street, North Point, Hong Kong. We will address your concern and attempt to resolve any problem.

LINKS TO SFAFT BV WEB SITES AND THIRD PARTIES

Please note that SFAFT BV or SUBWAY® web sites may contain links to other web sites for your convenience and information. SFAFT BV does not control those sites or their privacy practices. SFAFT BV’s privacy policy cannot and does not apply to external Web areas. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the SFAFT BV privacy policy. We encourage you to review the privacy policy of any company or web site before submitting your Personal Information. Some third parties may choose to share their personal data with SFAFT BV; that sharing is governed by that third party’s privacy policy.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you in this Privacy Policy, by email, or by means of a notice on our home page.